China Regulatory Research · Industrial Robotics

Industrial Robotics: documentation and language requirements in China

Machinery and robotics entering China require Chinese-language operating and safety documentation, with safety terminology tied to the wording of the governing standards. The general anchor is Article 27 of the Product Quality Law, which requires Chinese product identification and Chinese warning instructions for products that can endanger persons or property if used improperly.

Authority SAMRRetrieved 2026-09-04
Compiled from public sources

This page is compiled from public official sources and has not yet been checked line by line against the Chinese originals by a reviewer with Chinese regulatory reading capability. Every claim carries a source and a retrieval date so you can verify it yourself; confirm before relying on it for a filing or an external commitment.

Language requirements by document type

Each row states what was established, the provision it rests on, and when it was retrieved. Rows marked to verify are ones this research could not settle against an official provision — they are shown rather than omitted.

DocumentChinese requiredDetailBasisSource
Warning instructions on the machine and in the manualRequired Article 27, item (5) requires products that may damage themselves or endanger persons or property if used improperly to carry warning marks or Chinese warning instructions. Industrial robots sit squarely inside that description, which makes the Chinese warning text a compliance artefact rather than a convenience for the operator. Product Quality Law of the People’s Republic of China (as amended 29 December 2018), Article 27, item (5)www.cnipa.gov.cn2026-09-04verifiable
Product identification on the machine or packagingRequired Article 27, items (2) and (3) require the product name and the manufacturer name and address to be marked in Chinese, and require specifications, grade and principal constituent names and contents to be marked in Chinese where the product characteristics and conditions of use call for it. Where the buyer needs to know before purchase, the information must be on the outer packaging or supplied in advance. Product Quality Law (as amended 2018), Article 27, items (2) and (3)www.cnipa.gov.cn2026-09-04verifiable
Safety terminology in operating documentationRequired GB 11291.2-2013, the Chinese standard covering safety requirements for industrial robots at the level of robot systems and integration, is recorded as in force with an implementation date of 1 November 2014. Where a standard governs safety concepts, the Chinese wording attached to those concepts is not free for a translator to choose: it is inherited from the standard, and drifting from it makes the manual and the standard describe different things. The standard text itself was not read; its number, title, status and implementation date were verified from the national standards platform.GB 11291.2-2013, Robots and robotic devices — Safety requirements for industrial robots — Part 2: Robot systems and integrationopenstd.samr.gov.cn2026-09-04verifiable
Interface and on-screen textNot required No provision was located that specifically mandates Chinese for robot interface strings. The recurring problem here is not a language mandate but a mismatch: the manual describes a control by one name and the screen shows another, so an operator following the manual cannot find the control. Interface strings are also where identifiers matched in code get translated by mistake. Recorded as a negative finding: absence of a located provision is not proof that none exists.No specific provision locatedwww.samr.gov.cn2026-09-04portal only

About the source markers

verifiable
The link opens the provision itself — you can check that row by clicking it.
portal only
The link opens the authority's portal. It confirms the body and the scheme, but the specific reference or status on that row cannot be verified from that page alone.

Terminology consistency across submissions

Safety wording in this sector is inherited, not authored. Where a national standard defines a safety concept, the Chinese term attached to it comes from the standard, and the operating manual, the machine markings and the training material all have to use the same one. GB 11291.2-2013 remains in force for robot systems and integration, so its vocabulary is still the reference point for that layer.

  • Product Quality Law (as amended 2018), Article 27, item (5) — warning marks or Chinese warning instructions are required for products that may endanger persons or property if used improperly.
  • GB 11291.2-2013 — in force; safety requirements for industrial robots at the robot system and integration level.
The check that matters is not whether the Chinese reads well but whether the same safety concept carries the same term in the manual, on the machine, on the screen and in the training material. A manual that is internally consistent but diverges from the machine markings still leaves the operator with two vocabularies.

openstd.samr.gov.cn · retrieved 2026-09-04

Where companies get this wrong

01

An English manual is acceptable for professional operators

Article 27, item (5) requires warning marks or Chinese warning instructions for products that may endanger persons or property if used improperly. The provision is written around the hazard, not around the sophistication of the buyer.

www.cnipa.gov.cn
02

Safety terms can be improved if the improvement is clearer

Where the term comes from a governing standard, a clearer rendering is still a different term from the one the standard uses. That divergence is what makes a manual and a standard describe different things.

openstd.samr.gov.cn
03

Interface text and the manual can be translated separately

They can be, and that is usually how the mismatch arises. Nothing in the requirements forbids it; the cost lands on the operator who reads a control name in the manual that does not appear on the screen.

www.samr.gov.cn

What documentation problems have led to

No public case naming a document or language problem as the stated cause was found for this sector. What follows is the regulatory position, recorded without predicting outcomes.

Product marking

Chinese product name, manufacturer name and address are required on the product or its packaging, and Chinese warning instructions are required where improper use may endanger persons or property. No public case was located tying an enforcement action to robot documentation language.

www.cnipa.gov.cn
Safety standard

GB 11291.2-2013 is recorded as in force for robot systems and integration. Whether divergence from its terminology has been raised in an inspection was not established from public sources.

openstd.samr.gov.cn

Common questions

Does the operating manual have to be in Chinese?

The provision we can point to directly is Article 27, item (5) of the Product Quality Law, which requires warning marks or Chinese warning instructions where improper use may endanger persons or property. Whether every part of a manual falls inside that wording is a question we would not answer with more confidence than the text supports.

Retrieved 2026-09-04

What has to be marked in Chinese on the machine itself?

Product name and manufacturer name and address, under item (2). Specifications, grade and principal constituents follow under item (3) where the product characteristics and conditions of use require them.

Retrieved 2026-09-04

Which standard governs safety terminology for robot systems?

GB 11291.2-2013 covers safety requirements for industrial robots at the robot system and integration level and is recorded as in force, implemented 1 November 2014.

Retrieved 2026-09-04

Is there a Chinese-language requirement for the HMI?

We did not locate one, and we record that as a negative finding rather than as a conclusion that none exists. The failure we see in practice is mismatch between screen and manual rather than absence of Chinese.

Retrieved 2026-09-04

Our previous manual was approved. Can we reuse the terminology?

Check what standard it was written against before reusing it. Terminology inherited from a superseded standard reads correctly and cites a reference that no longer governs, which is the harder failure to notice.

Retrieved 2026-09-04

Can you certify our documentation meets Chinese safety requirements?

No. We can set out what the cited provisions and standards require, and where your material does not correspond to them, with a source for each point. Certification and legal determinations belong to the competent authority and to qualified professionals in China.

Retrieved 2026-09-04

What this research did not settle

The following could not be established against an official source in this round, and so was not written into the findings above. It is listed so you can see where the research stops.

  • The text of GB 11291.2-2013 was not read; only its number, title, status and implementation date were verified.
  • GB 11291.1 was not separately verified in this pass.
  • Whether a full operating manual, as distinct from warning instructions, carries an explicit Chinese-language mandate was not established.
  • No provision specific to robot interface or HMI language was located; recorded as a negative finding.
  • CCC certification scope for robots and robot systems was not confirmed at document level.

Sources

  • National standards full-text disclosure (openstd.samr.gov.cn)
  • China National Intellectual Property Administration, laws section (cnipa.gov.cn)
  • State Administration for Market Regulation (samr.gov.cn)

Retrieved 2026-09-04

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About this page

This page presents regulatory research intended to help companies understand documentation requirements in a target market. It does not constitute legal advice and is not a substitute for qualified legal counsel.

All regulation numbers, effective dates, and status indicators on this page carry a source and a retrieval date. Regulations may change after that date. For determinations of legal effect, the official-language text and the current rules of the competent authority govern.

Before this material is used for filing, certification, or any external commitment, we recommend review by a licensed attorney in the target market.

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